TFC-ESHQ-RP RWP-C-03, ALARA Work Planning_TF… · TFC-ESHQ-S_SAF-C-02, document the hazards identified and the controls required to mitigate the radiological hazards. 4. Incorporate

RPP-27195 ALARA WORK PLANNING Manual

Document Page Issue Date

ESHQTFC-ESHQ-RP_RWP-C-03, REV M-14

1 of 43May 31, 2016

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TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE ................................................................................................................ 2 2.0 IMPLEMENTATION ..................................................................................................................... 2 3.0 RESPONSIBILITIES ...................................................................................................................... 2 4.0 PROCEDURE ................................................................................................................................. 2

4.1 Radiological Review and Approval of Work Documents .................................................. 2 4.2 Risk Screening .................................................................................................................... 4 4.3 Radiological Work Planning/Work Document Preparation ................................................ 6 4.4 ALARA Management Worksheet Preparation ................................................................. 22 4.5 Dose Estimates .................................................................................................................. 24 4.6 Dose Tracking ................................................................................................................... 26 4.7 ALARA Reviews .............................................................................................................. 27

5.0 DEFINITIONS .............................................................................................................................. 31 6.0 RECORDS .................................................................................................................................... 32 7.0 SOURCES ..................................................................................................................................... 32

7.1 Requirements .................................................................................................................... 32 7.2 References ......................................................................................................................... 33

TABLE OF TABLES

Table 1. Tank Farms Radiological Risk Screening Criteria. ..................................................................... 35

TABLE OF ATTACHMENTS ATTACHMENT A – HEALTH PHYSICS HOLD POINTS ..................................................................... 36 ATTACHMENT B – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY

CONCENTRATION .................................................................................................................. 39 ATTACHMENT C – TYPE C MOCK-UP GUIDELINES ........................................................................ 41 ATTACHMENT D - DEVELOPING RWP VOID LIMITS, SAFE CONDITION LEVELS, AND

ACTION LEVELS ..................................................................................................................... 42

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ESHQ ALARA WORK PLANNING


TFC-ESHQ-RP_RWP-C-03, REV M-142 of 43

May 31, 2016 1.0 PURPOSE AND SCOPE

(7.1.1, 7.1.2)

This procedure establishes the Tank Operations Contractor (TOC) as low as reasonably achievable (ALARA) process for TOC operations and maintenance work planning in accordance with 10 CFR 835 and HNF-5183. This process is utilized to minimize personnel exposures to ionizing radiation and to limit the spread of radioactive contamination to the work place and environment. The process is intended to ensure reasonable efforts have been conducted to ensure radiological hazards that are significant and/or unique to particular work activities have been clearly identified and documented. These hazards should become the basis for incorporation of adequate controls to mitigate the consequences to the workforce. This procedure applies to personnel who plan, prepare, review, or perform radiological work in TOC facilities and is to be used in conjunction with TFC-OPS-MAINT-C-01 and TFC-PRJ-SUT-C-02.

2.0 IMPLEMENTATION

This procedure is effective on the date shown in the header. 3.0 RESPONSIBILITIES

Responsibilities are contained within Section 4.0. 4.0 PROCEDURE 4.1 Radiological Review and Approval of Work Documents

Radiological work activities meeting the HNF-5183 Glossary definition of radiological work, are to be reviewed by the Radiological Control Organization to identify and incorporate radiological requirements and radiological hazard controls. All radiological work is to be screened. Screening for determination of radiological work risk-ranking is accomplished by use of the process defined in TFC-ESHQ-RP_RWP-C-01. NOTE 1: Personnel approving radiological work documents created using this procedure shall have received training specific to the review and approval criteria. The appropriate approval process must be applied based on the risk level assigned (e.g., high risk work must be approved via the Joint Review Group process).

Project/Facility Radiological Control

1. Review and approve work documents for tasks involving: Work on contaminated or potentially contaminated facilities

or systems Work in radiological buffer areas (for contamination) Work in radiation, high radiation areas, and very high

radiation areas.

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Work in contamination, high contamination and airborne

radioactivity areas. This includes partial body entry into contamination and high contamination areas.

Work in contaminated or potentially contaminated soil,

including soil disturbing activities such as soil smoothing (e.g., raking, grading, compacting, or similar), and hand or mechanical digging/drilling at any depth located in radiologically controlled areas.

Packaging or un-packaging of radioactive material. Work in any area where there is a high probability of

radioactive material being present. Work requiring health physics (HP) hold points. See

Attachment A for hold point criteria and implementation guidelines.

2. Review and approve technical procedures authorizing or initiating any

work that requires the handling of radioactive material or which requires access to Radiation Areas, HRAs, Contamination Areas (CAs), High Contamination Areas (HCAs) or Airborne Radioactivity Areas.

3. Where technical procedures governing emergency response actions encompass more than one project (i.e., Abnormal Operating Procedures and Emergency Response Procedures) radiological review and approval shall include the Radiological Control Program Company Technical Authority or designated person.

4. Discuss applicability of selected and solicited Lessons Learned to the work activity with Radiological Control Work Planner AND Radiological Control First-Line Manager for all work determined to be High Radiological Risk and those Medium Radiological Risk evolutions selected at the discretion of project radiological control management.

Radiological investigative or characterization surveys, performed exclusively to establish radiological conditions of a work area or location, are not considered “work” requiring a work plan and may only require an ALARA Management Worksheet and Radiological Work Permit based on screening criteria, provided that the following activities are not performed:

Changing or manipulating plant-installed systems or component(s), i.e., valve

manipulation

Manipulating or disassembling equipment

Opening or closing a system or component other than hinged access doors/covers or pit penetration plugs

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Bolting/unbolting, welding, hoisting or rigging

Fabrication, removing fasteners

Connecting instrumentation to equipment or components

Decontamination.

Shielding radiological sources to reduce dose rates; or excavation.

4.2 Risk Screening

4.2.1 Low Radiological Risk Work documents for low risk activities may be used in repeat work without additional radiological review and approval as long as: The work document has received radiological control review and approval

Work scope and processes governed by the work document have not changed

Radiological conditions in the work area and controls specified in the work document

have not changed since review and approval.

Planner/Field Work Supervisor/Operations Engineer

1. Review with the radiological control subject matter expert the planned work activity to ensure it falls within the low radiological risk criteria.

Radiological Controls 2. Assign an existing RWP to the work OR Work with the planner to develop a new RWP for the work in accordance with TFC-ESHQ-RP_RWP-C-04.

Planner 3. Incorporate radiological controls into the work instructions per Section 4.3.

NOTE: The radiological control representative performing low risk work planning must have completed the “Low Risk Radiological Work Planner” qualification card #350190 or have a radiological control representative who has completed the qualifications review and co-sign the applicable documentation.

Radiological Controls 4. Approve the work.

4.2.2 Medium Radiological Risk

NOTE: The radiological control representative completing medium radiological risk work planning must have completed the “Medium/High Risk Radiation Work Planner” qualification

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card #350191 or have a radiological control employee who has completed the qualifications co-sign the applicable documentation.

Radiological Controls 1. Review the planned work activity using the unmitigated radiological

hazards to ensure it falls within the medium radiological risk criteria.

NOTE: Unmitigated radiological hazards are the actual (or potential) radiological conditions without regard to the effects of additional controls. Examples of additional controls include administrative actions in work documents/training, containment installation, decontamination, temporary ventilation system operation, temporary shielding, etc. Permanently installed facility systems controls are not considered an additional control for purposes of reducing radiological risk categorization.

2. Based on the scope of work and the survey data available, develop a DRAFT of the ALARA Management Worksheet (AMW) (A-6003-904).

Radiological Controls/ Work Planning Team

3. As part of the Job Hazard Analysis (JHA) development discussed in TFC-ESHQ-S_SAF-C-02, document the hazards identified and the controls required to mitigate the radiological hazards.

4. Incorporate input gathered during the planning process into the AMW, as needed.

Radiological Controls 5. Develop or assign an RWP for the work scope.

Planner 6. Work with Radiological Controls to incorporate appropriate work steps and hold points into the work document to mitigate radiological hazards and to implement radiological control requirements identified and developed for the job.

7. Work documents for medium risk activities may be used in repeat work orders without additional radiological review and approval as long as: The original work document has received radiological control

review and approval

Work scope and processes governed by the original work document have not changed

Radiological conditions in the work area and controls specified

in the work document have not changed since review and approval.

4.2.3 High Radiological Risk

NOTE 1: The radiological control representative completing high risk planning must have completed the “Medium/High Risk Radiation Work Planner” qualification card #350191 or have a radiological control employee who has completed the qualifications co-sign the applicable documentation.

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NOTE 2: Repetitive work determined to be High Radiological Risk may receive approval using the truncated JRG process contained in TFC-ESHQ-RP_ADM-C-11.

NOTE: The following requirement is not meant to include material mounted on an underground waste tank (e.g., breather filters, tank riser flanges, etc.).

Planner/Radiological Controls/Field Work Supervisor

1. When removing material/equipment from within an underground radioactive waste storage tank, categorize the work activity and plan as high risk unless an exception is approved by the applicable Level 1 Manager.

2. For high radiological risk work, complete Section 4.2.2, steps 2 through 6 of this procedure, and participate in the Joint Review Group review in accordance with TFC-ESHQ-RP_ADM-C-11.

3. If a mock-up is to be used, ensure that the Operations Level 2 manager has reviewed and documented the need for, and level of, the mock-up to be used, on the mock-up attributes form (A-6002-598).

4.3 Radiological Work Planning/Work Document Preparation

The radiological work planning process should ensure that anticipated dose to general employees does not exceed the administrative control levels specified in HNF-5183, Table 2-1. The primary method used to maintain exposures ALARA shall be physical design features (e.g., confinement, ventilation, remote handling and shielding). Administrative controls shall be employed only as supplemental methods to control radiation exposure. (7.1.1)

Planner/Document Owner/Radiological Controls/Field Work Supervisor/Operations Engineer

1. Ensure procedures are developed and implemented to ensure work is commensurate with existing and potential radiological hazards created by the activity and are consistent with the education, training, and skills of the individuals exposed to the hazard. (7.1.1)

2. Apply the following hierarchy of controls in the order listed when planning radiological work: (7.1.1) Design features Engineered/physical controls Administrative controls Protective clothing.

NOTE 1: It shall be assumed that all systems currently or previously connected to waste tanks or waste transfer systems are potentially internally contaminated. NOTE2: Application of fixatives, keeping surfaces damp (misting, spritzing), damp rags are examples of effective methods of controlling the spread of contamination, but are not considered an engineered control.

3. When breaching radiological systems or components that are contaminated or potentially contaminated, ensure that a minimum of

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one engineered control is in place to ensure adequate contamination control and worker protection have been applied. In lieu of the use of an engineered control, the use of respiratory protection and appropriate personal protective clothing is required. Approved engineered controls for breaching contaminated systems include: Confinement Systems

Ventilation (permanently installed or temporary) General (e.g., building exhaust and/or air flow

patterns) Gloveboxes and fume hoods Portable air movers (e.g., point capture).

Containments Glove bags, sleeving, tents, or glove boxes.

4. Where breaches of systems are planned and it is impractical or

impossible to employ engineering controls, obtain approval to use alternate controls in lieu of respiratory protection by the project Radiological Control Manager.

5. When engineered or physical controls are utilized, it may be appropriate to employ a combination of engineering controls and protective clothing.

6. Ensure specified fixatives have been evaluated and listed in RPP-11192, “Tank Farms Chemical Compatibility Evaluation”.

7. Develop contingency plans to address potential radiological issues that may arise during work. For low risk work, this can be accomplished through the

RWP preparation process For medium and high risk work, contingencies identified by

the work planning team will be documented in AMW and work instructions.

8. Incorporate controls into controlling work documents (e.g., Work

Instructions, technical procedures) to verify the effectiveness of engineering controls as appropriate (e.g., air sampling, contamination surveys, radiation surveys).

4.3.1 Radiation Exposure Considerations

Radiological Controls 1. Obtain survey data from the most current radiological survey report or

work history records.

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a. If reliable survey reports are unavailable, request a pre-job survey, as needed.

b. If survey data is not available or inadequate, and history and process knowledge is inadequate to properly plan the work, plan the work using the high risk assumptions with the highest level of radiological controls incorporated into the work instructions.

Planner/Document Owner/Radiological Controls/Work Planning Team

2. Consider the following techniques (not an all-inclusive list) to reduce personnel radiation exposure. a. Delete unnecessary work. This may require obtaining changes

in technical specifications to reduce time in radiation areas. b. Develop special tooling to reduce time in, or increase distance

from, radiation fields.

Work Planning Team c. Specify work to be performed outside of radiation areas to the maximum extent practicable.

Radiological Controls/ Engineering/Work Planning Team

d. Specify use of temporary shielding. NOTE: The following analysis is to make a determination if more exposure will be incurred during the installation and removal of shielding than if the work evolution is performed without the use of temporary shielding.

1) Perform an analysis documenting the benefit of

applying temporary shielding where use is anticipated. 2) Include expected exposure for completion of work

without use of temporary shielding, projected exposure for completion of work with application of temporary shielding (including exposure anticipated from installation).

3) Where it is not practical to perform this analysis

describe the reasoning in the AMW.

e. Identify the need for a mock-up or special briefings.

4.3.2 Contamination Control Considerations

Document Owner/ Radiological Controls/ Work Planning Team

1. Consider controlling contamination at the source using radiological containment devices (for specific criteria of radiological containments, see TFC-ESHQ-RP_RWP-C-02), fixatives, or high-efficiency particulate air (HEPA) filtered ventilation (i.e., when breaching known contaminated or potentially contaminated systems or components, ensure that a minimum of one engineering control is employed is in place to ensure adequate contamination control and worker protection has been applied).

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2. Base contaminated soil work controls on the known or potential

transferable contamination levels and duplicate work controls for similar work with similar known or potential removable contamination levels.

3. Include provisions in the JHA and/or specified radiological controls addressing the need for checks, inspections, or contingencies for the presence of unanticipated liquid or contamination before handling any part of equipment that has been in contact with tank waste as uncontaminated.

Radiological Controls 4. Specify the following if radiological containment devices will be used: Type of containment required Special instructions needed for containment fabrication and/

or installation Containment certification requirements (drapes are not

certified) When the containment is required to be certified/re-certified If appropriate, radiological conditions necessary for opening

the containment. For example, if a glove bag is to be opened and used as a drape containment, the work document shall specify the conditions necessary for opening the glove bag and when it shall be re-certified

Radiological conditions necessary for containment removal,

(e.g., decontaminate to 50,000 dpm/100 cm2 beta/gamma or use HEPA-filtered ventilation for glovebag collapse)

When the containment, including drapes, is to be removed.


5. Consider the following when working on pressurized systems. a. Ensure criteria for pre-job pressure testing of pressurized

systems and components that impact radiological conditions if failure were to occur during system operation or testing are incorporated into the work document, as appropriate.

b. Ensure pressure sources connected to radiologically

contaminated systems during operations, maintenance, or testing includes provisions for monitoring pressure and temperature.

c. Ensure pressure sources include provisions for pressure relief

or regulation to preclude over-pressurization of the system, hoses, jumpers, etc.

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d. Consider the use of an enclosure around temporary systems, joints, or other likely leak points.

6. Specify provisions for debris collection and control where there is a

possibility of fixed contamination being present and work evolutions could liberate solid debris, such as paint chips or flakes.

Work Planning Team 7. Consider human factors and ergonomics for the entry and exit phases of a work evolution. This includes, but is not limited to: Providing adequate space and convenience to safely don PPE Establishing posting boundaries that are representative of

expected spacing needs Providing layout, tables, and laydown areas that are conducive

to the release of personnel, equipment, and material Ensuring that survey instruments and the number of HPTs

assigned to perform release surveys are adequate Scheduling work activities in such a manner as to minimize

congestion at entry and egress points.

4.3.3 Use of Sleeving The use of heavy plastic sleeving is an effective method of controlling contamination during the removal of long-length contaminated equipment, in-tank video cameras, and other items removed from waste tanks, pits, and other contaminated tank farm structures. Sleeving is widely used as an ALARA tool in the handling of contaminated items. Proper use of sleeving facilitates the transfer of objects, protecting tools and equipment from contamination; or packaging items for disposal. TFC-ESHQ-RP_RWP-C-02 gives guidance on the use of containment, which includes sleeving.

Radiological Controls 1. Incorporate sleeving using a graded approach.

2. Determine removable contamination values.

3. Identify relative stability of contamination.

4. Identify scope of operation.

5. Select appropriate sleeving category.

6. Document sleeving selection in ALARA Management Worksheet, Section IV, D.

7. Document reasoning for deviation from the recommended sleeving methods in the AMW Section IV, D.

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May 31, 2016 4.3.4 Airborne Radioactivity Control Considerations

(7.1.1)

The following operations have the potential to generate airborne radioactivity when accomplished on surfaces with removable or fixed contamination: High-speed abrasive operations (e.g., grinding and sawing, use of flapper wheels)

Hot cutting (e.g., carbon arc and plasma arc)

Welding

Dust producing operations, such as wire brushing and abrasive blasting

Moderate work activity (i.e., resuspension factor of 1E-07 cm-1) where dry contamination

levels exceed 800,000 dpm/100 cm2 beta-gamma or 1500 dpm/100 cm2 alpha

Decontamination.

In these cases, the total contamination values should be considered when estimating potential airborne radioactivity concentrations. In addition, the chemical form of the contamination may decrease its stability relative to the potential for generating airborne radioactivity. Evidence indicates that systems that have been exposed to plutonium oxide or that have received an oxalic acid flush or treatment tend to contain contamination that becomes airborne very easily. However, the chemical form of contamination is not normally known prior to commencing work. A conservative approach to controlling exposure to or potential release of airborne radioactivity should be taken in these instances.


1. Consider the following practices to reduce airborne radioactivity levels: Fully enclosed radiological containments HEPA filtered ventilation Performing activities under water Application of wetting agents or fixatives.

2. Determine potential airborne radioactivity concentration per Attachment B, or per TFC-ESHQ-RP_RWP-C-04, Attachment A.

3. Reference RPP-53480, “Tank Operating Contractor Workplace Air Monitoring Standards Technical Basis Document,” and facility-specific workplace air monitoring documents to determine air sampling requirements.

4. Where guidance from step 3 above does not contain sufficient information for the intended scope of work, develop a monitoring plan or similar document detailing air sampling/monitoring requirements to include the following as necessary:

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Type of monitoring (e.g., CAM, grab sample, fixed head sampler)

Location of sampling equipment Frequency of monitoring.

NOTE: The techniques of Attachment B are not applicable to determining thoron daughter concentrations.

5. When it is suspected that thoron daughters may be present at concentrations that must be managed (i.e., 0.2 Working Level) and historical characterization data is not available, consider precautionary posting of an airborne radioactivity area (ARA) for the control of thoron daughters.

NOTE 1: Movement of flexible jumpers has historically been a source of airborne radioactivity release and/or contamination spread. NOTE 2: Changing radiological conditions can be expected when disconnecting nozzles and/or jumpers or when removing them from the pit.

6. Determine appropriate respiratory protection measures if work: Will be performed in a posted ARA or

Will result in the concentration of airborne radioactivity,

above natural background, exceeding or likely exceeding 20% of the derived air concentration (DAC) values listed in Appendix A or C of 10 CFR 835.

7. Specify use of respiratory protection and air sampling for work

activities where engineering controls and source term characterization data cannot be verified, or where changing conditions are anticipated.

4.3.5 Voluntary Respirator Use

See TFC-ESHQ-S_IH-C-05 for requirements for voluntary use of respirators.

4.3.6 Beta Radiation Hazards NOTE 1: Direct (contact) handling of items with beta radiation hazards should be avoided unless reviewed and approved by a work planning team as part of the work planning process.

NOTE 2: Air-fed hoods and respirators are acceptable protective clothing for beta radiation but should not be used solely for beta radiation protection.


1. Implement controls to minimize exposure to beta radiation whenever personnel may receive an extremity exposure of 500 mrem or be exposed to a shallow dose rate of 500 mrem/hr.

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2. Consider beta shielding whenever personnel are working on items that have contacted (or been contacted by) tank waste.

3. Consider the following techniques to reduce personnel beta radiation exposure (not an all-inclusive list): a. Place a layer of plastic or rubber (containment, glove bag,

heavy plastic bag, face shield, protective eye-wear, air-fed hood, and respirator) between the worker and beta radiation source.

b. Use shielded gloves. c. Use extension tools.

4. Ensure work documents governing work where personnel may be exposed to beta radiation specify precautions for minimizing and monitoring beta radiation exposure.

4.3.7 High Radiation Area Considerations

NOTE: Physical access controls are only applicable to those HRAs/VHRAs where radiation levels could result in an individual receiving an equivalent dose to the whole body in excess of 1 rem (.01 Sv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

Radiological Controls 1. When work documents direct a breach of a high radiation area boundary or creation of a new high radiation area, establish high radiation area controls in accordance with TFC-ESHQ-RP_MON-C-11 (e.g., removal of pit cover blocks, removing radiological samples from shielded containers, or removal of tank riser shield plugs 6 inches in diameter).

2. Specify the use of High Radiation Area Establishment Checklist (A-6005-915) in work documents when the new HRA will be left unattended.

3. Specify requirements for closeout inspections of high radiation area prior to access closure, if the high radiation area will be secured in a manner that would prevent unassisted exit by personnel (e.g., padlocking a vault door).

4.3.8 Radiological Survey Requirements Steps in this section are not intended to cover all conditions or situations warranting radiological surveys. Professional judgment should be used when specifying radiological survey requirements to ensure monitoring of radiological conditions is sufficient to maintain exposure to radiological hazards ALARA. Many radiological surveys are performed as skill based work during accomplishment of work. General work practice surveys are not required to be specified in the work document.

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May 31, 2016 4.3.8.1 General Contamination Surveys

NOTE: The location of surveys is normally not specified, but if specific information is required, the location will be specified. Work documents should specify contamination surveys.


1. Specify a transferable contamination survey using the transferable contamination determination methods described in TFC-ESHQ-RP_MON-C-20 when working with known or potentially contaminated soils.

2. Specify removable contamination survey requirements when a work operation is expected to spread contamination or when the survey data is necessary to determine the radiological controls required for subsequent work steps.

NOTE: Surveys are not required during remote entry into fluid systems. Examples of remote entry include, but are not limited to, jumper removal and cutting that is performed using remote tooling.

3. Specify a removable contamination survey at initial fluid system entry; for highly contaminated systems, perform a smear of the areas, surveys of wipe-down material may be used as an indicator of contamination levels.

4. If radiological conditions have changed since the last survey was performed, specify removable contamination surveys when entering potentially contaminated areas that contain known and potentially contaminated systems, such as pits or vaults.

5. Specify locations and frequency of removable contamination surveys during planned electrical outages and/or primary exhauster fan maintenance. Component-specific survey locations to consider should

include breather filters, pits, and other potential release points associated with the planned activity.

Survey frequency should be based on the maintenance activity and longevity of the outage, at a minimum, before and after work completion.

6. Specify removable contamination surveys when operations known to

spread contamination are specified, such as machining, filing, and grinding.

7. Specify removable contamination surveys of previously unexposed surfaces when removing equipment/components from areas where radioactivity from previous spills may have not been completely removed, or when uncovering potential sources of contamination, such as removal or disassembly of potentially contaminated components.

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8. When removable contamination levels in excess of 100 times HNF-5183, Table 2-2 values are expected, perform additional surveys for removable contamination commensurate with work operations. Some examples of additional surveys may include

containment exteriors, radioactive material packaging, and radioactive material travel paths.

9. Specify removable contamination surveys prior to opening glove bags.

10. Specify maximum removable contamination levels allowed before removing a glove bag, de-posting a drape containment, or containment tent in accordance with TFC-ESHQ-RP_RWP-C-02 or TFC-ESHQ-RP_MON-C-18, when necessary.

11. Specify Partial Body Entry requirements where necessary. Apply

limiting conditions appropriate for the work area posting. Area Controls Partial entry to a CA is performed from within an RBA for

contamination control. Partial entry to a HCA is performed from within a CA. Survey Requirements The Entry Zone receives radiological surveys before and

after entry. When performing multiple entries across a boundary during

an entry activity, the PPE may be monitored to ensure contamination is not spread/transferred out of the contaminated area.

Upon completion of a partial entry activity, the PPE is

removed and a survey is performed, concentrating on areas of the body involved in the entry (e.g., hands, arms, front of torso, etc.).

Upon final exit from the CA, or at completion of a CA partial entry activity, a whole body survey is required after all PPE has been removed.

4.3.8.2 Alpha and Hard-To-Detect Contamination Surveys

If survey data is not available, and surveys cannot be performed for the planning of the work, then plan the work using the high risk assumptions with the highest level of radiological controls incorporated into the work instructions.

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Radiological Controls 1. Specify alpha and/or Hard-To-Detect (HTD) contamination surveys when work scope or location requires alpha and/or HTD contamination surveys.

2. Refer to facility/project technical basis documents to determine locations or work scopes that require alpha and/or HTD monitoring. a. In the absence of a facility/project technical basis, refer to

RPP-52322 for areas and activities exempt from dual survey (beta/gamma and alpha).

b. Refer to RPP-53057 for HTD survey protocols.

4.3.8.3 Airborne Radioactivity Surveys

Radiological Controls 1. Specify airborne radioactivity surveys when operations are likely to

generate airborne radioactivity. This includes working with dry, distributed, removable contamination: ≥800,000 dpm/100cm2 beta-gamma 1500 dpm/100cm2 alpha. Wet, distributed removable contamination: 64 mr/hr, open window, beta-gamma 4200 dpm/100cm2 alpha.

NOTE: Results for airborne radioactivity surveys taken when contaminated soil levels exceed these values may be used to adjust bioassay or work controls, using a graded approach.

2. In the special case of transferable contamination and contaminated soils, specify airborne radioactivity surveys when: 200,000 dpm/100 cm2 transferable beta/gamma ≥10 dpm/100cm2 transferable alpha when Th-232 is known or

suspected to be present, or ≥100 dpm/100cm2 transferable alpha if other than Th-232 is

known or suspected to be present.

3. Specify airborne radioactivity surveys when opening known dry contaminated systems in a drape or walk-in CA.

4. Specify airborne radioactivity surveys during contaminated pit access, disconnecting/removing pit jumpers, pit demolition, and pit cleaning.

5. Specify airborne radioactivity surveys when opening or upon initial entry into areas containing radioactive piping if a piping breach in the area is believed to exist.

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4.3.8.4 Radiation Surveys

Radiological Controls 1. Specify gamma and/or beta radiation surveys when operations likely

to significantly change radiation levels are performed, such as:

Movement of highly radioactive material

Opening waste transfer or storage system components Installation/modification/removal of shielding Removal of highly contaminated piping from plant

component Radioactively contaminated liquid movement Draining of waste transfer systems.

2. Specify gamma radiation surveys be taken when contact radiation levels on material (including decontamination rags) or equipment removed during work is expected to be 100 mrem/hr, including when removal of components or interferences could expose previously inaccessible areas with radiation levels 100 mrem/hr.

3. Specify contact gamma radiation surveys to be taken on radioactive piping following insulation removal.

4. Specify neutron radiation surveys to be taken where personnel may be exposed to neutron radiation, such as when handling neutron test sources.

5. Specify gamma and/or beta radiation controls, when necessary, for activities that are not normally performed (e.g., changing SCBA bottles in a CA).

4.3.9 Remote Monitoring

Rapidly changing radiation levels may be encountered when removing long length equipment, tools, cameras, material, and other items from waste tanks where they have come into contact with tank waste. In order to provide early indication of rapidly rising and/or unexpected radiation levels, consideration should be given to the use of remote monitoring techniques.

Radiological Controls 1. Consider the use of remote monitoring techniques when removing long-length equipment, tools, cameras, material, and other items from waste tanks.

NOTE: Remote monitoring may take the form of telemetry dosimeters, portable radiation detection instruments with remote readout capabilities, or other monitoring methods. Methods should be capable of providing

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radiological control personnel with early information that can be used to direct and control work activities.

2. When remote monitoring is to be used, clearly communicate instructions for the use of such monitoring methods in controlling work documents. The Work instructions, RWP, or other instruction should clearly communicate: Monitoring equipment to be used (e.g., telemetry dosimetry)

Location of monitoring devices

Other pertinent information critical to the specific

application.

3. Establish and document in the controlling work documents any predetermined levels where additional actions can be taken to prevent unnecessary exposure to workers. Examples of contingencies include, but are not limited to: Application of additional shielding

Use of long reach tools

Restrictions on direct handling by personnel

Additional decontamination through washing or other means

(e.g., spray wands).

4.3.10 Excavation in Radiological Areas and RCAs

Radiological Control Work Planner

1. Screen the planned excavation activity in accordance with DOE 0344 and TFC-ESHQ-S-STD-30.


2. Review excavations to evaluate the radiological conditions and the need for radiological controls during excavation activities.

3. Review Waste Information Data System (WIDS) data for nearby sites and note precautions.

4. Specify continuous HPT coverage for all excavations inside: Radiological Buffer Areas (for contamination control) Soil Contamination Areas Underground Radioactive Material Areas Contamination Areas.

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5. Determine posting requirements and survey frequency for excavation activities as follows: Inside Radiologically Controlled Areas with no other

radiological postings in the area of excavation, the area shall be posted as a Radiological Buffer Area. Soil must be surveyed at least every 6 inches of excavation elevation. Project/Facility Radiological Control Managers may determine on a case-by-case basis no additional radiological postings to the RCA are required.

For Underground Radioactive Material Areas, the area shall be posted as an RBA for contamination control as a minimum. Soil must be surveyed at least every 2 inches of excavation elevation.

For Soil Contamination Areas or Radiological Buffer Areas for contamination control, the area shall be posted as a Contamination Area.

For Contamination Areas, the area may remain as a CA during excavation with specific action or safe condition levels requiring posting the area as a High Contamination Area should these levels be encountered during excavation.

6. Include the following controls for active excavations (e.g., approved work instructions) that are within five feet of active waste transfer components and lines that are either: not double valve isolated and controlled by Operations (e.g., tamper seals), or cannot be verified as adequately controlled. NOTE: High radiation area controls are not required for waste transfer components and lines that have been verified as either disconnected, inoperable, or abandoned. a. Establish high radiation area posting and controls in

accordance with TFC-ESHQ-RP_MON-C-11, encompassing the excavation site; OR

b. Deploy shielding to the excavation sufficient to reduce

radiation levels below high radiation area conditions throughout the transfer AND establish radiation monitoring at least once per shift. (7.1.1)

4.3.11 Hold Points

NOTE: Criteria for radiological hold points are contained in Attachment A.


1. Incorporate radiological hold point steps into work documents for steps that require action by the radiological control organization to prevent any of the following:

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Radiation exposures in excess of administrative control levels

Airborne radioactivity levels in excess of 10 times the DAC

values provided in Appendices A and C of 10 CFR 835 Work that can result in the spread of contamination to the

environment requiring notification as specified in TFC-OPS-OPER-C-24.

a. Format hold point steps in work documents as specified in

TFC-OPS-MAINT-C-01.

4.3.12 RWP Limiting Conditions

Radiological control limiting conditions typically provide conditions which, if encountered, require some action, such as stopping work. Examples of radiological control limiting conditions would be encountering unanticipated levels for whole body dose rate, extremity dose rate, and removable surface contamination.

Limiting conditions are applied to radiological conditions encountered by workers. These limiting conditions are established for worker protection, and thus are applied at the worker location.

Limiting conditions for RWPs employed at the TOC are Action Levels, Safe Condition Levels, and Void Limits. See Attachment D for further detailed direction.

4.3.12.1 Void Limits

Radiological Controls/ Engineering

1. Develop Void Limits for all Radiological Work Permits to establish limiting radiological conditions encountered by workers that necessitate immediate cessation of work.

2. Use the direction in Attachment D to develop void limits. 4.3.12.2 Safe Condition Levels


1. Determine contingency plans for Radiological Work Permits, based on Attachment D criteria to establish limiting radiological conditions that necessitate cessation of normal work.

2. Define actions to be taken that allow work area to be placed in a safe condition and to mitigate the conditions which initiated the Safe Condition response.

3. Specify actions to notify Shift Manager and Radiological Control First Line Manager upon reaching Safe Condition Levels.

4. Obtain approval from the Shift Operations Manager AND the Project Radiological Control Manager prior to resumption of work.

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1. Develop Action Levels for Radiological Work Permits, based on Attachment D criteria, to identify levels where actions are performed to maintain conditions within expected and planned radiological levels.

2. Specify actions to be taken upon reaching defined Action levels.

3. Specify that actions taken need to restore conditions below defined Action Levels.

4.3.13 Mock-Ups

Mock-ups provide a method for verifying specialized skills, work practices, adequacy of work documents, and special tools needed to ensure work is completed safely while maintaining radiation exposure ALARA.

Planner/Radiological Controls

1. Consider mock-ups for complex radiological work performed in HRAs or involving work on highly contaminated systems or working in a HCA. Jobs that should be considered for use of mock-ups include: Work that could result in an individual receiving >250 mrem

or in a collective dose >1000 mrem Work that could result in a reportable spread of contamination

to the environment. Reportable levels are specified in TFC-OPS-OPER-C-24

First-time or complex work on radiological systems using new

tooling and/or techniques Work that will result in rapidly changing radiological

conditions Work that, if a mock-up was accomplished, would

significantly reduce the time or the number of workers required for the job.

2. Determine the degree of mock-up required during work planning.

A graded approach should be taken when determining the type of mock-up required as follows. Proof of Concept: An activity designed to demonstrate or

determine that an option or method for completing a work activity will function as intended prior to field deployment in radiological areas.

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Type A: Lecture or conference style mock-ups can be accomplished by an instructor or technically competent individual.

Type B: Hands-on mock-ups should be conducted by an

instructor or technically competent individual who will demonstrate the use of a tool or equipment and then the workers set up and operate the tool or equipment under his/her direction. This could be accomplished on a workbench or tabletop. When the workers are familiar with the setup and operation of the tool, they would set up the tool individually without assistance from the instructor. Minimal or no protective clothing would be used.

Type C: This full-scale mock-up should be conducted by an

instructor or technically competent individual to closely simulate the actual work area, with the same radiological work requirements as the actual job. Personnel will be dressed in the same protective clothing and follow the same steps in the work procedure and RWP (see Attachment C).

Field Work Supervisor 3. Obtain or construct mock-ups, as required. Physical mock-ups may

consist of a small bench-top device or a full scale model of the work area, including all interferences, services, containments and tooling to be encountered during actual work.

Field Work Supervisor/ Radiological Controls

4. Perform mock-up evaluation and document on A-6002-598. a. Assign personnel to act as mock-up evaluators, as needed. b. Ensure instructors, management personnel or technically

competent personnel evaluate the mock-up to verify work can be performed safely in the field.

Operations Level 2 Manager and Facility/ Project Radiological Control Manager

5. Review and approve mock-up documentation on A-6002-598.

4.4 ALARA Management Worksheet Preparation

The AMW is a tool used to ensure all reasonably achievable methods of reducing the worker’s exposure are considered during the development of the work instructions. The AMW is not a substitute for approved work instructions. The AMW is used to document the logic, thought processes, assumptions, and methods of determining decisions regarding radiological hazards identified or anticipated during a planned work evolution. The AMW is a mechanism to document that administrative and engineering control and optimization methods have been applied during work procedure development to assure that the ALARA process is fully integrated into the development of operational work plans, procedures, and protocols. The AMW is a means to document formal plans and measures for applying the ALARA process to occupational doses. The AMW should not be used to direct work activities. Controls determined

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necessary to maintain occupational exposures ALARA need be incorporated into Radiological Work Permits, detailed work instructions, procedures, or other technical work documents.

NOTE: AMWs are effective for one year or until the AMW is revised or corrected, whichever occurs first. At the end of the one year period, the AMW shall be reviewed/ revised, if necessary, and be reissued or discontinued.

Radiological Controls 1. Prepare an AMW for activities that: Meet medium or high radiological risk screening criteria Are considered significant radiological work determined

to be infrequent or first time activity (requires enhanced line and radiological control management oversight during initiation and conduct of work)

Are management requests Are radiological control requests.

2. Provide the AMW information to the work planner or planning team (if applicable) for review as part of the Job Hazard Analysis roundtable meeting, and update, as necessary.

3. Sign each AMW before its initial use and after each revision or correction.

4. Route the AMW for approval as follows: AMW preparer Peer Review(s) Line Manager (Field Work Supervisor or Higher) Radiological Controls Manager JRG Chairperson (High Risk).

5. Incorporate identified lessons learned into work instructions or other work document.

6. Verify the AMW has not exceeded the review frequency.

7. Forward a copy of the AMW to the work planner.

4.4.1 Pen and Ink Changes for Modifying Previously Approved ALARA Management Worksheets While computer-generated AMW revisions are preferred, pen and ink changes are allowed, as necessary, to ensure continuity of work. Pen and ink changes are ONLY authorized on job-specific AMWs for changes that do not have adverse effects on the hazards associated with the job.

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Radiological Controls/ Radiological Control Supervisor/Lead Health Physics Technician/Health Physics Technician

1. Make the necessary changes to the AMW with a reproducible blue or black ink pen.

2. Line out, initial, and date the AMW revision number and enter the next sequential number revision number.

3. Obtain approval for the change in accordance with Section 4.4, step 5. NOTE: Approval per telecon is acceptable. Approval may be obtained from the respective on-call manager(s), if necessary.

4. Document approvals in the AMW Review section of the AMW.

5. Copy the signed AMW and distribute copies to the appropriate work documents.

6. Incorporate the change(s) into a computer-generated revision as soon as practicable.

4.5 Dose Estimates

4.5.1 Whole Body Dose Estimates


1. Obtain data, as needed, to perform the whole body dose estimate. This data includes, but is not limited to: Description of work steps Approximate stay times Number of exposed workers Dose rate(s) in the work area.

2. Obtain survey data from the most current radiological survey report or work history records. a. If reliable survey reports are unavailable, request a pre-job

survey, as needed. b. If insufficient survey data is available to develop an accurate

dose estimate, plan the work using the high risk assumptions with the highest level of radiological controls incorporated into the work instructions.

Radiological Controls 3. Estimate a collective whole body dose for the job.

a. For collective whole body dose estimate 200 person-mrem,

perform dose estimate using simple calculations, previous job history, or pre-job survey data.

b. For collective whole body dose estimate between 200 and

1,000 person-mrem, perform dose estimate by:

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Obtaining previous collective whole body dose history from the same or similar jobs

Performing simple calculations based on previous

radiological survey data and estimated stay times.

Performing calculations that take into account varying whole body dose rates for multiple tasks within the job and estimated stay times associated with those tasks.

c. For collective whole body dose estimate >1,000 person-

mrem, perform dose estimate by:

Breaking the job down into its component parts.

Estimating the whole body dose for each task by multiplying the estimated stay time and the dose rate in the area where the task is being performed.

Document the method used to estimate the collective

dose.

4. Document the whole body dose estimate and method on the ALARA Management Worksheet (AMW) (A-6003-904).

4.5.2 Extremity Dose Estimates

Development of extremity dose estimates should be considered using a graded approach if any of the following conditions are likely to exist during the performance of work activities: A worker is likely to receive an extremity dose greater than 3000 mrem during the period

of finger ring issuance

Extremities may receive shallow dose more than ten times greater than the deep dose received by the chest and greater than 500 mrem.


1. Obtain data, as needed, to perform the extremity dose estimate. This data includes, but is not limited to: Description of tasks and work steps Approximate stay times Number of exposed workers Dose rate(s) in the work area.

2. Obtain survey data from the most current radiological survey report or work history records. a. If reliable survey reports are unavailable, request a pre-job

survey, as needed.

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b. If insufficient survey data is available to develop an accurate dose estimate, then plan the work using the high risk assumptions with the highest level of radiological controls incorporated into the work instructions.

Radiological Controls 3. Estimate individual extremity dose for the job. a. For individual extremity dose estimate 3000 mrem, perform

dose estimate using simple calculations, previous job history, or pre-job survey data.

b. For individual extremity dose estimate >3000 and 5000

mrem, perform dose estimate.

1) Obtain previous individual extremity dose history from the same or similar jobs.

2) Perform simple calculations based on previous

radiological survey data and estimated stay times.

3) Perform calculations that take into account varying extremity dose rates for multiple tasks within the job and estimated stay times associated with those tasks.

c. For individual extremity dose estimate >5000 mrem, perform dose estimate

1) Break the job down into its component parts.

2) Estimate the extremity dose for each task by

multiplying the estimated stay time and the dose rate in the area where the task is being performed.

3) Develop a table to display how the estimated

individual extremity dose was determined.

4. Document the extremity dose estimate and method on the ALARA Management Worksheet (AMW) (A-6003-904).

5. If it is believed that extremity dose controls are necessary to effectively complete the work, create applicable controls in the Radiological Work Permit.

4.6 Dose Tracking

Radiological Control 1. Monitor whole body collective dose periodically for work with dose

estimates above 200 person-mrem.

2. Conduct an ALARA review if accumulated whole body dose exceeds the triggers established in Section 4.7.

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NOTE 1: Attendance at ALARA reviews should include the facility ALARA chairperson or coordinator (when possible); cognizant radiological control personnel; WRPS Hanford Atomic Metal Trades Council (HAMTC) safety representative (when possible); and at least one representative from each craft involved in the critical elements of the job. Additional subject matter representatives should be added as determined necessary by the field work supervisor. Craft representatives should (in as much as possible) have participated in the job to be involved in the ALARA review. Industrial Safety and Health (IS&H) organization should be notified for attendance when the driver for the review is dealing with tank waste (Chemical ALARA). These personnel, in conjunction with the daily post-job reviews, should provide adequate information to accurately complete the ALARA review. The function of the facility ALARA chairperson or coordinator may be fulfilled by cognizant radiological control personnel. If craft representatives are unavailable for the ALARA review meeting, and their supervisor or field work supervisor has sufficient knowledge of what took place during the work, either supervisor may represent the craft(s) at the meeting.

NOTE 2: An equivalent critique or event investigation report that fulfills the requirements of this section may be used rather than an ALARA review. An ALARA review shall be completed when:

Work is stopped due to a reportable radiological event (defined in

TFC-OPS-OPER-C-24) and revisions are required to engineered or administrative work controls

Accumulated dose exceeds 150% of estimated job dose for jobs where the dose estimate

is >200 person-mrem During the job it is anticipated that a trigger level for a higher radiological risk category

will be exceeded Requested by management Feedback is received for significantly improving radiological performance during

completion of remaining work governed by the work document A Radiological Work Permit void limit is exceeded The actual dose encountered for the job differs from the predicted dose by more than

25%, if the actual collective dose is 1.0 person-rem or greater The job produces an actual collective dose of 5 person-rem or greater Stop radiological work authority was exercised by any worker during the performance of

the work A reportable radiological occurrence occurred during the performance of the work

Significant lessons learned are identified during work or during radiological

surveillances and assessments associated with the work

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The work document was screened as high radiological risk. NOTE: If an ALARA review has been performed during the job, and no additional benefit can be obtained from conducting another ALARA review meeting at the end of the job, the previously completed reviews may be utilized, with concurrence from the facility ALARA Chairperson or designee, to create an ALARA review for the end of the job.

Scheduler/Work Window Manager, or Planner (at 222-S)

1. Notify cognizant radiological control when field work has been completed for all medium and high radiological risk work documents.


2. Based on the above criteria, determine if an ALARA review is required.

3. When an ALARA Review is conducted for any of the following reasons, ensure that steps 4-6 of this section are completed prior to resumption of work activities: Work is stopped due to a reportable radiological event

(defined in TFC-OPS-OPER-C-24)

A Radiological Work Permit void limit is exceeded

Stop radiological work authority was exercised by any worker during the performance of the work

A reportable radiological occurrence occurred during the performance of the work

Any skin and/or personal clothing contamination

Requested by management

During the job, it is anticipated that a trigger level for a higher radiological risk category will be exceeded.

4. Identify those actions that need completion and implementation prior

to resumption of work: Changes to Radiological Work Permits, Work Plans, or other

applicable documents

Changes to engineering controls (e.g., ventilation, containment)

Changes to personal protective equipment (respiratory protection

Revision of dose estimates.

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5. Modify AMW showing changes to controls, dose estimates, PPE, contamination levels, airborne radioactivity estimates, limits or any other AMW section that were revised due to an in-progress review being performed.

6. Clearly describe long-term corrective actions, recommendations for process improvements, and/or changes to facility design/layout, or other changes which may be accomplished subsequent to resumption of the work evolution under review.

Field Work Supervisor (May be a Scheduler, or Planner at 222-S)

7. Schedule an ALARA review upon completion of the field work portion of the work document.

8. Notify the following personnel of the pending ALARA review: Radiological Control Work Planner

HAMTC Safety Representative At least one representative from each craft involved in the

critical elements of the job Industrial Safety and Health (IS&H)

Facility ALARA Chairperson and/or Coordinator.

Field Work Supervisor/OE/SM (May be a Scheduler, or Planner at 222-S)

9. Conduct an ALARA review meeting as soon as possible after the work is complete, preferably within 30 calendar days, but no later than 60 calendar days after completion of the field work portion of the work document, unless an extension is approved by the operations manager or radiological control manager.

a. Gather data to reflect the work practices and ALARA measures that were effective, and define those needing improvement.

b. Solicit input from workers involved in the job for

identification of good practices and areas for improvement that can be incorporated into the continuous work improvement process.

c. Keep a roster of the ALARA review meeting attendees and

include as part of the ALARA review document.

Radiological Controls 10. Support the Field Work Supervisor by providing information pertinent to completion of the ALARA Review. a. Obtain an ALARA review number from HLAN share drive

TFRWP/ALARA Reviews/AR Index.

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b. Comparison of predicted to actual radiation exposure.

11. Assist the Field Work Supervisor/OE/SM in the conduct of the ALARA Review.

Field Work Supervisor/OE/SM

12. Document the results of the ALARA Review using the WRPS Post-Job/Post ALARA Review form (A-6005-438).

13. Obtain review and approval of the ALARA Review to include: Cognizant field work supervisor/OE/SM Facility/project ALARA chairperson or delegate Facility/project radiological control manager or delegate.

14.

Place the original, completed ALARA review documentation with the facility records, and forward a copy to the: WRPS and facility/project ALARA chairpersons Radiological Work Planner Work record.

Radiological Controls/ Work Team

15. Revise AMWs, as needed, for future use.

RWP Preparer 16. Revise RWPs, as needed, for future use.

Planner/Document Owner

17. Revise work documents, as needed, for future use.

Field Work Supervisor/OE/SM

18. Generate a Lessons Learned in accordance with TFC-OPS-OPER-C-28, where ALARA Reviews indicate improvements should be made in future evolutions.

Field Work Supervisor/Project Radcon, Project ALARA Reviewer

19. If an in-process ALARA review has been performed, complete and approve the ALARA review prior to resumption of work for review conducted for reasons stated in step 3.

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5.0 DEFINITIONS

Action levels. Action levels define radiological conditions where the job is suspended or specific actions are taken to ensure the radiological conditions, protective clothing, equipment, engineered controls, and monitoring are adequate to continue working and to prevent reaching the limiting safe conditions. Continuous health physics technician coverage. Continuous health physics technician coverage is defined as coverage sufficient to IMMEDIATELY influence or stop work based on observed radiological conditions or work practices. Engineered controls. The use of components and systems to reduce airborne radioactivity, the spread of contamination, and radiation exposure levels by using containments, ventilation, filtration or shielding. Entry Zone. The area where the worker is performing the partial body entry.

Excavation. Excavations include any operation in which earth, rock, or other material in the ground (below existing grade) is moved, removed or otherwise displaced by means or use of any hand tools, mechanical equipment or explosives. General area. The immediate work area. The use of “General Area,” as the term pertains to RWP usage applies to the immediate work area radiological conditions that will affect the workers in the completion of the prescribed job description. This would include dose rates and contamination levels within general travel paths to and from the immediate work. This will typically be a room, a designated area within a room (e.g., hood, bench top), general travel paths to and from the work location, and/or a reasonable area surrounding the work location (e.g., pit area) where the work is to be performed.

High risk assumptions. High risk assumptions are created using known radiological data combined with historic and process knowledge. These assumptions should envelop the worst case scenario, given the information available and conditions likely to be present, with the risk level (low, medium, or high) assigned based on those conditions.

Inefficiency factor. The estimated percent decrease in worker efficiency due to wearing respiratory protection. Intermittent health physics technician coverage. Intermittent health physics technician coverage is defined as coverage sufficient to monitor and verify radiological conditions at frequent enough intervals to exclude any reasonable potential for an unmonitored and significant change in radiological conditions. Intermittent coverage is routinely provided at the start and end of the job and any critical elements that may result in unmonitored and significant change in radiological conditions. Intermittent coverage is normally limited to work involving a low potential for contamination spread or significant changes in radiological conditions.

Localized radiological area. A radiologically controlled area that will not be entered into with the whole body. Partial Body Entry. Entry of any portion of the body into a CA from a RBA or into a HCA from a CA.

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Protection factor. The ratio of ambient airborne concentration to concentration inhaled of a given substance while wearing a respirator.

Reliable data. Data that reflects the radiological condition(s) of the area, work space, or location where radiological work will be performed. Resuspension factor. The resuspension factor is the ratio of the concentration of radioactive material in the air due to resuspension, to that on the surface.

Routine radiological work. Repetitious work for which the radiological risk does not vary enough between each performance of the activity to justify repetitive reviews.

Safe Condition Levels. Safe conditions are conditions that, when verified to be present, cause an immediate stop to normal work activities. The work area is placed in a stable condition using approved contingency plans. Selected Lessons Learned. Those previously documented Lessons Learned from existing databases. Solicited Lessons Learned. Those lessons learned from historical and process knowledge and experience not previously captured and documented. The intent is to capture “tribal knowledge” and incorporate them into formal documented lessons learned. Void Limits. An established limit on radiological conditions that, when verified to be present, cause an immediate cessation of work activities and movement of workers to a safe location

6.0 RECORDS

(7.1.1)

The following records are generated during the performance of this procedure: ALARA Management Worksheet (A-6003-904) Mock-Up Attributes (A-6002-598) High Radiation Area Establishment Checklist (A-6005-915) Post Job - Post ALARA Review (A 6005-438).

Records generated during the performance of this procedure shall be submitted to an approved RadCon Record Storage Area. The record custodian identified in the Company Record Inventory and Disposition Schedule (RIDS) is responsible for record retention in accordance with TFC-BSM-IRM_DC-C-02.

7.0 SOURCES 7.1 Requirements

1. HNF-5183, “Tank Farms Radiological Control Manual.”

2. RPP-MP-003, “Integrated Environment, Safety, and Health Management System Description for the Tank Operations Contractor.”

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1. ALARACT 5, “Tank Farm ALARACT Demonstration for Soil Excavation (Using Hand Tools).”

2. 10 CFR 835, “Occupational Radiation Protection.”

3. DOE-0344, “Hanford Site Excavating, Trenching and Shoring.”

4. HNF-55719, “Hanford Project Internal Dosimetry Project Manual.”

5. NUREG/CR-0041, “Manual of Respiratory Protection Against Airborne Radioactive

Material.”

6. RPP-52322, “TOC Technical Basis for Dual Survey Exemption.”

7. RPP-53057, “TOC Technical Basis for Evaluation of Hard-To-Detect Beta-Emitting Radionuclides.”

8. RPP-53480, “Tank Operating Contractor Workplace Air Monitoring Standards Technical

Basis Document.” 9. RPP-RPT-58717, “Partial Body Entry to Contaminated Areas Technical Basis

Document.”

10. RPP-11192, “Tank Farms Chemical Compatibility Evaluation.”

11. TFC-BSM-IRM_DC-C-02, “Records Management.”

12. TFC-ESHQ-Q_C-C-01, “Problem Evaluation Request.”

13. TFC-ESHQ-RP_ADM-C-11, “Joint Review Group.”

14. TFC-ESHQ-RP_MON-C-12, “Temporary Shielding.”

15. TFC-ESHQ-RP_DOS-C-03, “External Dosimetry.”

16. TFC-ESHQ-RP_DOS-C-08, “Supplemental Dosimetry.”

17. TFC-ESHQ-RP_MON-C-11, “High Radiation Area Controls.”

18. TFC-ESHQ-RP_MON-C-18, “Radiological Postings.”

19. TFC-ESHQ-RP_RWP-C-02, “Radiological Containment.”

20. TFC-ESHQ-RP_RWP-C-04, “Radiological Work Permits.”

21. TFC-ESHQ-RP-STD-03, “ALARA Decision Making Methods.”

22. TFC-ESHQ-S_IH-C-05, “Respiratory Protection.”

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23. TFC-ESHQ-S-STD-30, “Implementation of DOE-0344, Excavating, Trenching, and Shoring.”

24. TFC-OPS-MAINT-C-01, “Tank Operations Contractor Work Control.”

25. TFC-OPS-MAINT-C-02, “Pre-Job Briefings and Post-Job Reviews.”

26. TFC-OPS-OPER-C-24, “Occurrence Reporting and Processing of Operations

Information.”

27. TFC-OPS-OPER-C-28, “Lessons Learned.”

28. TFC-PRJ-SUT-C-02, “Operational Acceptance Test Preparation.”

29. TFC-ESHQ-RP_RWP-C-01, “Radiological Risk Screening.”

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Table 1. Tank Farms Radiological Risk Screening Criteria.

Low Risk Medium Risk High Risk Routine or repetitive

activities, such as tours and inspections or minor work activities, in areas with well-characterized and stable radiological conditions.

Tasks that do not meet any medium or high risk criteria.

Routine, repetitive analytical or maintenance activities performed in a fume hood that meet the criteria listed below: <50 mrem/hr @ 30

cm. Meets Alpha

worksheet per ATS-GD-106.

Meets color-coding per ATS-LO-090-103.

Will the estimated collective dose ≥500 person-mrem but <1000 person-mrem?

Will a respirator be worn for radiological purposes?

Will general area removable contamination be ≥100,000 but < 1,000,000 dpm/100 cm2 Beta-Gamma or ≥1000 but <2,000 dpm/100 cm2 Alpha?

First time or infrequent activities in a fume hood where general area removable contamination is estimated to be ≥100,000 but <1,000,000 dpm/100 cm2 Beta-Gamma or ≥2,000 but <20,000 dpm/100 cm2 Alpha?

Routine, repetitive Analytical or maintenance work in fume hoods where removable contamination is estimated to be >1,000,000 but 5,000,000 dpm/100cm2 Beta-Gamma or 10,000 to 100,000 dpm/ 100cm2 Alpha in the general area.

Will there be entry into areas where whole body dose rates are ≥ 100 mrem/hr but <1 rem/hr?

Is there a potential for release of radioactive material that exceeds Table 2-2 levels outside a CA, HCA, or ARA?

Will the estimated collective dose exceed ≥1,000 person-mrem?

Will predicted airborne radioactivity concentrations exceed ≥10 DAC OR result in an integrated exposure of over 200 DAC-hours?

Will general area removable contamination be ≥1,000,000 dpm/100 cm2 Beta-Gamma or ≥2,000 dpm/100 cm2 Alpha?

For first time or infrequent work in a fume hood, will general area removable contamination be ≥1,000,000 dpm/100 cm2 Beta-Gamma or ≥20,000 dpm/100 cm2 Alpha?

Routine / repetitive analytical or maintenance work in fume hoods where removable contamination is estimated to be >5,000,000 dpm/100cm2 Beta-Gamma or 100,000 dpm/ 100cm2 Alpha in the general area.

Will there be entry into areas where whole body dose rates are ≥1 rem/hr?

Is the work a first time or infrequently performed activity or are radiological conditions unknown and likely to result in changing radiological conditions?

When removing material/equipment from within an underground radioactive waste storage tank, the work activity shall be categorized and planned as high risk unless an exception is approved by the applicable Level 1 Manager? This requirement is not meant to include material mounted on an underground waste tank (e.g., breather filters, tank riser flanges, etc.).

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ATTACHMENT A – HEALTH PHYSICS HOLD POINTS

1.0 PURPOSE OF HOLD POINTS

Health physics hold points are incorporated into work documents for steps that require action by the radiological control organization to assess existing radiological conditions or prevent significant adverse radiological consequences during subsequent steps. The intended results of the action are: A. Prevention of radiation exposures in excess of administrative control levels.

B. Prevention of airborne radioactivity levels in excess of 10 times the DAC values

provided in Appendices A and C of 10 CFR 835.

C. Prevention of the release of radioactivity to the environment. 2.0 HOLD POINT CRITERIA

In support of these functions, the following activities require health physics hold points to be included in work packages when appropriate:

A. Initial certification of containment tents and glove bags.

B. Verification of contamination levels prior to removing a certified glove bag from an

installed component.

C. Actions taken to ensure airborne radioactivity levels do not exceed 10 times the applicable DAC values for radionuclides of concern in the work area.

D. Action to assess changing radiological conditions and ensure implementation of required

controls when it is anticipated a changing condition could result in failure to meet the intended results of 1.A, B, and C.

If there is a need for a health physics hold point other than those above, the health physics hold point needs to be cleared through the facility/project radiological control manager.

NOTE: Actions to ensure radiation exposures in excess of administrative control levels are prevented are being controlled by means other than work document hold points and include the following: Use of alarming electronic pocket dosimeters (EPD) for all entries made into areas where

the whole body dose rate exceeds 100 mrem/hr (all HRA entries), with the maximum integrated dose alarm set at 80% of the individuals remaining weekly or annual dose margin to the ACL or 100 mrem, whichever is more limiting.

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ATTACHMENT A – HEALTH PHYSICS HOLD POINT CRITERIA (cont.) Formal assignment of a health physics technician(s) during entries into high radiation

areas to provide monitoring, as necessary, during access to determine the dose rates to which the individuals are exposed.

3.0 RECOMMENDED HOLD POINT ACTION STATEMENTS

To assist in defining the text associated with health physics hold point actions, the following general guidance is provided: NOTE: See TFC-OPS-MAINT-STD-02 for hold point format.

A. Initial certification of containment.

Place the following step either:

Immediately after the step for installation of a containment tent or glove bag, or Immediately prior to beginning work inside of the containment tent or glove bag.

Health physics technician perform initial certification of containment in accordance with attached certification checklist.

_________________________ _________________________

Printed Name Signature Date

B. Removing a containment from an installed component.

Place the following step immediately prior to the step for removal of containment:

Health physics technician verify contamination levels inside the containment are less than (insert appropriate value).

_________________________ _________________________


C. Actions taken to ensure airborne radioactivity levels do not exceed 10 times the applicable DAC values for radionuclides of concern in the work area.

Place the following statements immediately prior to steps that may result in airborne radioactivity levels exceeding 10 times the applicable DAC values in the work area if omitted or improperly performed:

CAUTION: Omission or improper performance of steps XXX through XXX may (or is expected to, as appropriate) result in airborne radioactivity levels in excess of 10 times the applicable DAC values in the work area.

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May 31, 2016

ATTACHMENT A – HEALTH PHYSICS HOLD POINT CRITERIA (cont.)

Health physics technician ensure that the following control(s) is (are) in place prior to performing steps XXX through XXX:

_____ List control(s) used to ensure airborne radioactivity levels in excess of 10 times the

DAC values do not occur. Controls used to control airborne radioactivity include, but are not limited to, items such as applying fixative prior to breaching containment boundaries and performance of smoke testing to ensure direction of ventilation flow.

_________________________ _________________________


D. Verification of radiological controls.

Incorporate the following statement(s) as needed to ensure anticipated radiological conditions are within the controlling values/limits/assumptions used when planning the work.

Health physics technician perform a survey (dose rate, contamination, air sample as appropriate) to verify conditions are within (insert appropriate value) prior to continuing.

_________________________ _________________________


Health physics technician ensure that the following control(s) is(are) in place prior to performing steps XXX through XXX:

_____ List control(s) used to ensure work is performed within the controlling

values/limits/ assumptions used when planning the work.

_________________________ _________________________ Printed Name Signature Date

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May 31, 2016

ATTACHMENT B – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY CONCENTRATION

NOTE: The techniques of Attachment B are not applicable in determining Thoron daughter concentrations. 1. Determine if air sample data is available from similar jobs performed in the past.

a. If historical data is available, proceed to step 2. b. If historical data is unavailable, proceed to step 5.

2. Convert the airborne radioactivity concentration to a derived air concentration (DAC) fraction. 3. If the resultant airborne radioactivity concentration is 20% of a DAC (0.2DAC), respiratory

protection is required. 4. Document the method and results of the calculation of potential airborne radioactivity

concentration on the ALARA Management Worksheet (AMW) (A-6003-904). 5. When removable contamination values (representative of work surfaces) are available, estimate

the airborne radioactivity concentration with the following equation:

C = R Sc (4.5E-07 µCi/dpm)/CF

Where: C = estimated workplace air concentration (µCi/cm3) R = resuspension factor (cm-1); see Table B-1 for values Sc = removable activity per unit area (dpm/cm2), except when using vigorous work activities (e.g., chipping, high speed grinding, welding), or using a cutting torch, the total activity per unit area must be used

CF = confinement factor (unitless) from Table B-2. This factor takes into consideration whether the material is separated and confined while a worker is present or whether it is actually handled in the open.

Table B-1. Resuspension Factor.

R, cm-1 Work Description

1. E-08 Tours, hands-off inspections

1. E-07 Moderate activity, non-heat generating work, slow speed mechanical cutting, maintenance

1. E-06 Vigorous work activity, such as sweeping, grinding, flapper wheels, drilling

1. E-05 Cutting torch, welding, high pressure air

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May 31, 2016

ATTACHMENT B – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY CONCENTRATION (cont.)

Table B-2. Confinement Factor.

Condition Factor HEPA ventilated glove bag 100 Glove bag without HEPA ventilation 10 Clean wet rags on source of contamination, keeping material wet

10

Ventilated hood, portable HEPA ventilation (e.g., point source ventilation)

10

HEPA ventilated bullpen or environmental barrier

10

Plastic covering on material 10 Bullpen or environmental barrier, without HEPA ventilation

1

Bench top or open work area 1

NOTE: The use of controls as means of contamination confinement SHALL NOT be used to reduce the initial radiological risk value determination of an activity. Relative radiological risk must be determined by using the unmitigated hazards as defined in Sections 4.1 and 4.2.

6. Document the method and results of the calculation of the potential airborne radioactivity

concentration on the ALARA Management Worksheet (AMW) (A-6003-904).

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ATTACHMENT C – TYPE C MOCK-UP GUIDELINES Simulate actual field work conditions during conduct of the mock-up to the maximum extent practicable. a. Pre-job briefings are held exactly as they would be on the actual job. b. Work document requirements are followed, as written, unless it is impractical to perform the

work steps using the mock-up. This includes taking actions required by radiological hold point steps.

c. Stay times and pre-determined dosimeter readings are included in the mock-up if they are

established for any work steps. Extremity dosimetry, if required, should be worn during the mock-up.

d. If radioactive waste will be created during work, personnel are expected to minimize and handle

the waste properly. e. Simulated radiation levels will be posted in the mock-up to familiarize personnel with the actual

levels in the work area. This can be accomplished by using radiological warning signs and/or “hot spot” labels. Radiological warning signs and labels shall be clearly marked, such as “For Mock-up Purposes Only.”

f. If liquids or wet waste will be encountered during the job, ensure the mock-up will contain the

liquid to simulate actual field conditions. g. Abnormal and/or casualty situations should be simulated to assess the actions taken by involved

personnel. h. If workers do anything during the mock-up that would result in either a gross spread of

contamination, skin or clothing contamination, or excessive radiation exposure, mock-up is stopped and the worker(s) briefed before continuing. If necessary, the worker(s) will repeat the mock-up.

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May 31, 2016

ATTACHMENT D - DEVELOPING RWP VOID LIMITS, SAFE CONDITION LEVELS, AND ACTION LEVELS

Discussion A graded progressive approach in developing RWP void limits, safe condition levels, and action levels is used to ensure worker exposure remains ALARA, using Table D-1. Void limits are established for worker protection and thus apply at the worker location, not on equipment unless the worker is required to be at that location. Void Limits are most restrictive, then Safe Condition levels and finally Action Levels are least restrictive in the graded approach to providing a structured approach to controlling radiological work. The work planning process is used to develop and apply these values as needed and appropriate to assure worker and facility safety are integrated into work plans and represents a balanced approach to regulatory compliance and operational flexibility, allowing work to proceed at `deliberate speed’ (along a planned course of events, including contingencies for foreseeable variations). Void limits are established to define the upper radiological safety boundary of the planned work activity. Safe Condition Levels are developed to balance worker safety and facility safety, and are based on void limits. Action Levels are developed as a mechanism to control the work activity radiological parameters during actual work performance to ensure sound Conduct of Radiological Operations, while maintaining worker and workplace conditions ALARA. They are based on void limits. Definitions:

Radiological conditions: Actual or known radiation levels, airborne radioactivity concentrations, radioactive contamination levels, quantities of radioactive material, or individual doses from radiological hazards based on measured values. Expected radiological conditions: Radiological conditions that are either known to be present, or unknown but expected, planned, anticipated, predicted, or potentially present, and will be able to be verified based on measured or measurable values in the field during the work activity.

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ATTACHMENT D - DEVELOPING RWP VOID LIMITS, SAFE CONDITION LEVELS, AND ACTION LEVELS (cont.)

Table D-1. Void Limit/Safe Condition Level/Action Level Summary.

Whole Body Dose Rate at the Worker Location

Area Posting Void Limit Safe Condition Level Action Level Buffer Area/RMA 5 mrem/hr N/A 3 mrem/hr

Radiation Area 100 mrem/hr 80 mrem/hr 50 mrem/hr

High Radiation Area 1,000 mrem/hr 800 mrem/hr 500 mrem/hr

Extremity Dose Rate at the Worker Location

Extremity Dose Rate Void Limit Safe Condition Level Action Level Extremity dose rate

that will result in 5,000 mrem

Extremity dose rate that will result in 3,000 mrem

500 mrem/hr

Removable Contamination Levels at the Worker Location

PPE Category Void Limit Safe Condition Level Action Level

No PPE ≥1,000 dpm/100 cm2 βγ, or ≥20 dpm/100 cm2 α

N/A > D dpm/100 cm2 βγ, or > D dpm/100 cm2 α

Single Set PPE (With or without

respiratory protection)

≥100,000 dpm/100 cm2 βγ, or ≥1,000 dpm/100 cm2 α

≥80,000 dpm/100 cm2 βγ, or ≥500 dpm/100 cm2 α


Double Set PPE ≥800,000 dpm/100 cm2 βγ, or ≥1,500 dpm/100 cm2 α

≥600,000 dpm/100 cm2 βγ, or ≥1,000 dpm/100 cm2 α


Double Set PPE w/APR

≥480 mrad/hr/100 cm2 βγ, or ≥50,000 dpm/100 cm2 α



Double Set PPE w/PAPR

≥8,000 mrad/hr/100 cm2 βγ, or ≥1,750,000 dpm/100 cm2 α

≥6,000 mrad/hr/100 cm2 βγ, or ≥50,000 dpm/100 cm2 α


Double Set PPE w/ Positive

Pressure Supplied Air

≥8,000 mrad/hr/100 cm2 βγ, or ≥1,750,000 dpm/100 cm2 α



Double Set PPE w/SCBA

≥50,000 mrad/hr/100 cm2

βγ, or ≥5,000,000 dpm/100 cm2 α


≥25,000 mrad/hr/100 cm2

βγ, or ≥25,000 dpm/100 cm2 α

NOTE: Values other than those listed in Table D-1should be justified in writing and approved by the Project RadCon manager, based on written justification, using the AMW or other documented technical justification.

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